What is a Manifest Hold? (And How to Avoid One)

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Importers can have manifest holds placed on their shipments for failing to file an ISF on time, missing documents, or incorrect information. Learn more about manifest holds and how a customs broker can help you avoid them.
February 17, 2022
Last Modified: December 31, 2024
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Import delays can be frustrating. The Import delays can be frustrating. The key to avoiding most holds during customs clearance is being aware of what causes them in the first place. Some factors might be out of your control, but taking the right steps can minimize the occurrence of manifest holds. 

Key Takeaways

  • Manifest holds occur when shipment documents are missing, incorrect, or illegible, or when Importer Security Filings (ISF) are not submitted on time.
  • These holds delay customs clearance and can result in fines of up to $5,000 per discrepancy.
  • To avoid manifest holds, importers should carefully review critical documents like the Bill of Lading (BoL), Packing Lists, and Certificates of Compliance.
  • Customs Trade Partnership Against Terrorism (CTPAT) members are considered low-risk, reducing the likelihood of random inspection holds and facilitating faster clearance.

See how a proper review of import documents can minimize errors and help your company avoid delays and penalties. 

What is a Manifest Hold?

A manifest hold can refer to a few different types of delays. At a minimum, it is a standard delay enacted by an official from Customs and Border Protection (CBP) while they review a container’s import documents for accuracy. In that case, it’s probable the hold isn’t even reported to the customs broker. Most times it lasts less than 24 hours and causes no significant delays in further transportation plans. 

Manifest holds are one of four different types of holds that can be placed on incoming imports. Known as U.S. Customs Inspection Holds, they may be issued by CBP or other government agencies involved in import regulations for specific products. 

If the hold has been issued by the Consumer Product and Safety Commission (CPSC), one of five messages will be sent through ACE (Automated Commercial Environment). 

  • May Proceed
  • Hold Intact
  • Hold Intact with Document Review
  • Intensive Exam
  • Intensive Exam with Documents Required

The majority of shipments will receive the ‘May Proceed’ message. A good compliance history with the CPSC increases that possibility. 

What Causes a Manifest Hold?

The most common manifest hold is issued by CBP when they don’t receive an Importer Security Filing (ISF) on time or receives one that contains errors. The ISF is commonly sent by either the shipmaster or importer. A licensed customs broker acting as an importer of record may also submit it. 

Other times, CBP will issue a random manifest hold for a spot inspection. Since it’s logistically impossible for the agency to independently verify every container against its declared manifest, random inspections are the most practical option. If your shipment is chosen for such an inspection, you’ll just have to wait for the process to play out. 
The CPSC will issue a manifest hold for shipments of higher interest, such as those under strict regulations. The review process for CPSC holds is separate from standard manifest holds. More information on resolving CPSC holds can be found on our other page.

Want to Make Sure You Avoid a Manifest Hold on Your Imports?

Speak to one of our Licensed Customs Brokers and get personalized, 1-on-1 help importing your goods.

Will I Be Fined for a Manifest Hold?Will I Be Fined for a Manifest Hold?

Any cargo hold issued by CBP or a related government agency can result in a fine. Whether you receive a fine or not depends on why the hold was issued in the first place, the nature of the mistake, and how many of them were found. 

Manifest mistakes can cost a shipmaster or importer $5,000 for each discrepancy discovered. If your cargo does not comply with import regulations on a spot check, there are usually hefty fines issued by the overseeing agency, too. 

Even if your cargo is in compliance with all applicable regulations, disorganization of your documents or clerical errors may increase the hold time. In some cases, port authorities may even have to transfer your cargo to another facility while investigations are conducted. The inspection may not find any mistakes, but CBP might still assess a fine for delaying port activities and the storage of inspected cargo. 

Want to ensure your critical import data stays secure? File a CBP Confidentiality Request.

How Can I Avoid a Customs Manifest Hold?

The best way to avoid most manifest holds is to have a clear understanding of what causes them in the first place. A time delay on your shipments isn’t convenient, but a penalty on top of a time delay can spell financial disaster. Most of what you can do to avoid a manifest hold will also help you avoid penalties and fees from CBP or related agencies

Importers should pay special attention to these specific items:

  • Bill of Lading (BoL): This document should be checked for accuracy because the information on it is used to create the shipping manifest sent to U.S. Customs. Incorrect information could be transferred to a manifest and cause enough of a discrepancy to trigger a manifest hold. 
  • Packing List: This is the first step to getting a BoL. Multiple packing lists are usually made available to ensure cargo accuracy during all stages of shipment. Just like with a BoL, you want it to accurately reflect the actual cargo.
  • Certificates of Compliance / Certificate of Conformity (CoC): In the case of importing heavily regulated or commonly inspected cargo, a CoC can limit a hold time to 24 hours or less by showing proof that the cargo meets regulations for entry. 

If you are new to importing, get into the habit of double-checking documents and ensuring your compliance with regulations. Frequent importers with a good reputation of compliance are less likely to be caught in a spot check. 

For those who only import a few times a year, there is a greater chance of having your cargo randomly checked. Just be sure that all your papers are in order and the hold should get lifted within 24 hours. 

Working with a licensed customs broker is a good investment for avoiding holds and penalties in general. A broker can walk you through completing important documents, or even complete them on your behalf. It's almost a guarantee that fees and penalties from errors will cost you more than a customs broker. 

For more information on import documents, check out our article, “How to Clear U.S. Customs With Cargo.”

Join a Trade Partnership

Global trade has made the world a smaller place, but not necessarily a safer one. Ocean carriers, truck drivers, and rail operators have always had to contend with natural and man-made dangers. A growing awareness of the dangers of terrorism to U.S. security and that of its closest neighbors led to the establishment of the Customs Trade Partnership Against Terrorism (CTPAT) in 2001. 

CBP uses this partnership  to put safety regulations in place and enforce cargo security. As a voluntary partnership program, most members of the trade community, public or private, can join. Partners from the U.S., Mexico, and Canada agree to work with CBP to protect different parts of the trade industry. 

Members of CTPAT have to meet certain qualifications to be accepted. Most qualifications have to do with their security measures. Because CTPAT members are thought of as ‘low-risk’ to security, their shipments are less likely to be held up in U.S. ports of entry.

What is the Advance Vessel Manifest Rule?

Officially known as the 24-hour Advance Cargo Manifest Declaration Rule, this applies to vessels that will be transiting or docking to unload at a port of entry in the United States. 

The rule was put in place in 2002 and requires shippers (ocean carriers and NVOCCs) to send a cargo manifest to U.S. Customs 24 hours before the containers are loaded onto the ship in a foreign port. 

The rule applies whether the cargo is meant to be unloaded in a U.S. port of entry or is staying aboard while the ship docks temporarily on its way to another foreign port. The 24-hour notice window opens once a loading schedule has been set. 

If the vessel is making more stops before reaching the U.S., a manifest should be submitted at each port. Changes to the cargo manifests are expected with each additional BoL that gets added. 

A shipping manifest has information specific to its onboard cargo, including any special directions. The CBP Manifest Examination Team (MET) needs to review this information for possible risks. The MET also has the authority to put a shipment on hold if they need to ask for further documentation. 

If a vessel fails to submit its manifest on time or errors are found, penalties may include:

  • A cargo hold at the loading point (origin port)
  • Penalty fees against the carrier or NVOCC
  • Having the cargo seized by U.S. Customs for inspection
  • Unloading requests denied at port
  • Requiring cargo to be returned to its port of origin. 

Each of these penalties is likely to cause not just a time delay, but a hefty fine too. Both would be bad for your profit margins. 

Is your private import data actually public record? Check out our article Manifest Confidentiality: Do Import Records Affect Business?

What is a U.S. Customs Inspection Hold?

Any shipment hold issued by CBP directly or on behalf of a partner government agency (PGA) is a U.S. Customs Inspection Hold. There are different types of holds based on what triggers them, but they all amount to the same thing. A shipment is prevented from leaving a ship or the port until further investigation by CBP and port authorities. 

CBP uses a series of codes to identify the types of cargo being held, the status of a hold, who issued the hold, and more. A complete table of these disposition codes is available through CBP as a PDF document.

What are the Different Types of Inspection Holds?

Aside from a manifest hold, there are three other types of holds that may be placed on imports entering the U.S. by sea or air. Much like manifest holds, some of these may be issued as random spot checks. 

  1. PGA/Commercial Enforcement Hold: Issued by a Partner Government Agency (PGA) regulating specific imports. For example, the U.S. Department of Agriculture could issue a PGA hold on a container of rice for inspection. In many of those cases, the holds only last 24 hours, and goods are released with no penalties provided the inspection was clean. 
  2. Statistical Validation Hold: Issued if CBP suspects that the cargo declaration has errors, perhaps because it doesn’t match previous shipments of the same merchandise or there are discrepancies in weight or quantity. 
  3. CET (A-TCET) Hold: Issued by the Anti-Terrorism Contraband Enforcement Team when shipments are thought to include illegal materials. These could be items such as drugs, weapons, counterfeit currency, or others that could pose a danger to national security. 

Strictly sticking to import regulations and maintaining a secure and accurate manifest system can help you prevent some of these holds. 

Want to Make Sure You Avoid a Manifest Hold on Your Imports?

Speak to one of our Licensed Customs Brokers and get personalized, 1-on-1 help importing your goods.

Get Help on Shipping Documents With USA Customs Clearance

Customs manifest holds and audits can cost import companies upwards of $5,000 in penalties for a single shipment. Simple mistakes can turn a profitable venture into a hopeless money pit. 

Work with experienced and licensed customs brokers at USA Customs Clearance and invest in the future success of your business. Our brokerage services can help you avoid unnecessary and costly delays that could cost you thousands in lost revenue. Speak with one of our consultants 1-on-1 and get help with document completion, HTS codes, and more. 

Our other services include:

Give us a call today at (855) 912-0406 or submit a contact form online.  We’re here to help keep your businesses on the move and free from manifest holds.

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